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Home My WebLink About04-6119 o CHRISTOPHER GLASS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE JULIANE GLASS, Defendant : NO. 04- I., //9 CIVIL TERM NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LA WYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. CHRISTOPHER GLASS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE : NO. 04- (,,/11 CIVIL TERM JULIANE GLASS, Defendant DIVORCE COMPLAINT The plaintiff, Christopher Glass, by his attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa.C.S. ~~3301(c) AND 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Christopher Glass, who currently resides at 51 South Bedford Street, Carlisle, Cumberland County, P A 17013, since September 1, 2004. 2. Defendant is Juliane Glass, who currently resides at 4 West Main Street, Walnut Bottom, Cumberland County, P A 17266, since January 1, 2004. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on February 19, 1991 at Carlisle, Cumberland County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since July 6, 2003. 6. There have been no prior actions for divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. WHEREFORE, Plaintiff requests the court to enter a decr]~ ~ Carlesha R. Green 1t~~- Lucy Jo~~On-Walsh Supervising Attorney FAMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717)243-2968 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. 94904, relating to unsworn falsification to authorities. Date l~.. 3. Ot.{ Plaintiff ci.ht,~ l ~ Chflstopher.Glass t'-~to.... _' .to,. eo~... "~}.r..\1. - --- I"~. -..... ..., .,' J ,..... r.o .. ,-. ..... ~ :"1 ~ f~ . . ~i' r',." ~ .., I c) ,. - ",- (.) CJ "',) C:~.::") ("':") n "fj ::::J ;:.' - -II I 11;~ ~',~!.~ '1'1 ((:!~!:j :~-) rr, C".7 r'1 c-j I -...J --:;, -.. :n e CHRISTOPHER GLASS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LA W : IN DIVORCE :' NO. 04- f.,if'/ CIVIL TERM JULIANE GLASS, Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Christopher Glass, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party . I , 1210') DV Ri,eCtfullY su fnifl'd, ~ J.#W~ ~ r. CARLESHA R. GRE~ Certified Legal Intern ~ Date l~[Lk- (/ ANNE ONALD-FCI LUCY J HNSTON- WALSH THOMAS M. PLACE Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717-243-2968 ~"': I"i- ., ~ .. ~ ' j' \~~~, " (' " .'.~:' C) C' :~ .1 .,,< f"".,.,,", C;:;:) C.~~ J.:- ,::, r:::-i '. .; I --.J '-::1 ....,:,. ( ,.) a CHRISTOPHER GLASS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE JULIANE GLASS, Defendant : NO. 04-6119 CIVIL TERM CERTIFICATION OF SERVICE I, James R. Abbott, Certified Legal Intern, hereby certify that the Family Law Clinic served a true and correct copy of the Complaint for Divorce on Juliane Glass residing at 4 West Main Street, Cumberland County, Walnut Bottom, Pennsylvania, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested. Service was complete upon receipt by Juliane Glass on the 23rd day of December, 2004, as evidenced by the attached return reciept card with the article number 7003 3110 0004 5774 2686. -1- Janw R. Abbott C~fied Legal Intern -& ~~~~- . TH IMA LACE ROBERT E. RAINS LUCY JOHNSTON-WALSH AN1\rE MACDONALD-FOX Supervising Attorneys F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 ...a I:Q ..D nJ U.S. Postal Service", CERTIFIED MAIL" RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) OFFICIAL () i)..3P" /.7sf "3 .s-~\ . IS. .:T l'- l'- U1 postage $ =s- a a a RetUrn Reclept Fee (Endorsement Required) a RBSlrk:led Delivery Fee ..-=t (Endorsement Required) ..-=t rn Total Postage & Feea $ Certified Fee rn a a l'- u's~ ".:, \ '. :;;;.J -......, ,I\, '\. :'\ ~a:rf('> ~~L H~ \ \.'\" ~ \ . . omplete items 1, 2, and 3. Also complete 4 if Restricted Delivery is desired. . 'nt your name and address on the reverse so that we can return the card :.0 you. . Attach this carq to the back of the mallpiece, or on the front if space perHfCits. 1. ArtIcle Addressed to: fr~ r;;.t~ If ~-t ~ S1 /).Jf<Lr,.Ji St>-f~ PFJ )7J...~b D. Is elivery address different from item 1? If YES. enter delivery address below: 3. Service Type jiil" Certified Mail Cl I:xpress Mail trReglstered ~~eturn Receipt for Merchandise o Insured Mall Cl C.O.D. 4. Restricted Delivery? (Extra Fee) 0 Yes 2. Article Number (Copy from service label) ~. 7d(i3 3//6 OOOY .~77Y ;).~(?0 PS Fonn 3811, July 1999 Domestic Return Receipt 102595-99-M-1789 ~~ I f 4 6 (") 1':1 c. c;::> c.: = . "-: c:.n ~ <- .-\ -r.) [;:7 ~r --, I.r~ f", > i~i-l ;:--,; ~~/ ~"..- I Z --7 t":-~ , .-....1 : .~.: ~2~.' c.".) -)\ ~O ._~ -0 :;-';:0 ::J: .-':r -'''''Cl >c: ~ ..- .' -/ :z .t:'" ! \D ~""!!IIIt CHRISTOPHER GLASS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW DIVORCE JULIANE GLASS, Defendant : NO. 2004-6119 CIVIL TERM NOTICE TO DEFENDANT If you wish to deny any ofthe statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 33011d) OF THE DIVORCE CODE I. The parties to this action separated on July 6, 2003 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. I verify that the statements made in this affidavit are: true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904, relating to unsworn falsification to authorities. Date 7 - J. - {iC: ( , Christo her Glass, Plaintiff ~ <::~ c.r' ~:: ;;- - S?, -' -C -r1 f.1e _(JIO" "'U. ?:~~A (2\ "PO :3, N -0 ::;;: '-:? 1" ;r.:,; - CHRISTOPHER GLASS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW DIVORCE JULIANE GLASS, Defendant : NO. 2004-6119 CIVIL TERM AFFIDAVIT OF CONSENT 1. A complaint for divorce under S 3301 (c) and S 3301 (d) ofthe Divorce Code was filed on December 7, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry ofthe decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities. Date: I;(-~\- rt~ c~.lEL :--,.. ~.~- i~;:. Date:~ d- -a~ - 06 L CHRISTOPHER GLASS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW DIVORCE JULIANE GLASS, Defendant : NO. 2004-6119 CIVIL TERM WAIVER OF NOTICE AND INTENTION TO REQUEST ENTRY OF A DIVORCE UNDER ~ 3301 (c) OF ~ 3301 (d) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before the divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree is sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities. L .-,'! v:) SAlDIS, FLOWER & LINDSAY ATIORNE\'S'AT'lAW 26 West High Street Carlisle, PA II CHRISTOPHER GLASS Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA v. CIVIL ACTION - DIVORCE NO. 2004 - 6119 CIVIL TERM JULIANE GLASS Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under S 3301 (c) of the Divorce Code was filed on December 7. 2004. 2. The marnage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of fHing ann s'?-rvjr,e of the Com!-,!2int 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities.,/, Date 'lS:-00 q!n;~/J d;Jc'l~{~ liane Glass DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER& 3301 Ic) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, !a\vyer1s fees or expenses if I do not c1i=!im them before a divorce is granted. 3. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsiflca/ to ~uthontl~~. of Datel::::::--c6 / ~~ J lane Glass APR 0 '1 2(lJ) :--:..) '-'..} f:."\ --.J (.') en r~~<-'-' I I , I i JULlANE GLASS, I ['laiRliff De4YlJtlYl'(. ~ ~ /0. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 2004 - 6119 CIVIL TERM CHRISTOPHER GLASS, QgfOA9:lRt Plalt7f. df IN DIVORCE PROPERTY SETTLEMENT AND SEPARATION AGREEMENT THIS AGREEMENT is made this 1...'1- day of ~~, :2005, by and between JULlANE GLASS, of 4 West Main Street, Walnut Bottom, Cumberland County, Pennsylvania 17266, hereinafter referred to as Wife. and CHRISTOPHER GLASS, of \1. d, ~"i- 6l.,.52'1 ~'-" D;~(;, CI4 qll~, hereinafter referred to as Husband. RECITALS: R.1: The parties hereto are husband and wife, having been joined in marriage on February 14, 1991, in Carlisle, Pennsylvania; and R.2: A Complaint for Divorce has been filed in the Court of Common Pleas of Cumberland County, Commonwealth of Pennsylvania, to Number 04-6119, Civil Term; and R.3: The parties hereto desire to settle fully and finally their respective financial and property rights and obligations including, but not limited, 01 all matters between them relating to the ownership of real and personal property, claims for spousal support, alimony, alimony pendente lite; and / <=-SG-"'R4: The rties also dJSire to settle the' . sues of ;y.>tody of th~rminor childr,~, JORDAN, L HA, MA~NE, CO NIE, AL YSSA(~~ MACK.A:YL~, counseHees and /' ," -~ /~ / //~ /...-/- ./',.. _.,../ /",./ d the~g of any ai}O..ar(c1aims and po;sfule claims 99ainst the othere:;r against their NOW THEREFORE, in consideration of the covenants and promises hereinafter to be mutually kept and performed by each party. as well as for other good and valuable consideration 1 , I ~ -.--, and intending to be legally bound, it is agreed as follows: (1) SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place or places as he or she from time to time may choose or deem fit, free from any control, restraint or interference from the other. Neither party will molest the other or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceeding. Each party shall be free of the interference, authority or contact by the other as if he or she was single and unmarried except as maybe necessary to carry out the terms of this agreement. (2) DIVORCE: The parties acknowledge that the marriage is irretrievably broken and that they will secure a mutual consent no-fault divorce decree in the above-captioned divorce action. Upon the execution of this agreement, the parties shall execute and file an Affidavit of Consent and Waiver of Notice Forms, necessary to finalize said divorce. (3) DEBT: A: MARITAL DEBT: Husband and Wife acknowledge and agree that there are no other outstanding debts and obligations which are marital or for which the other might be liable incurred prior to the signing of this Agreement, except as follows: i. A loan for the purchase of a 1994 Chevrolet Astro Van to Credit Acceptance Corporation, formerly CPS. Husband shall pay the obligations on account of the loan for the parties' van to Credit Acceptance Corporation (CPS), by making timely monthly payments in at least the minimum amount required by the creditors until paid in full. Husband shall indemnify and hold Wife harmless on account of any loss with the van loan. B: Post Separation Debt: In the event that either party contracted or incurred any debt since the date of separation on July 6, 2003, the party who incurred said debt 2 shall be responsible for the payment thereof regardless of the name in which the debt may have been incurred. C: Future Debt: From the date of this agreement neither party shall contract or incur any debt or liability for which the other party or his or her property or estate might be responsible and shall indemnify and save the other party harmless from any and all claims or demands made against him or her by reason of debts or obligations incurred by the other party (4) MOTOR VEHICLES: Each party relinquishes any right, title and interest he or she may have to any and all motor vehicles currently in possession of the other party. Upon payment of the lien encumbering the 1994 Astro Van, which is presently jointly titled, Wife will execute any documents necessary to have that vehicle properly registered in Husband's name with the Pennsylvania Department of Transportation. Husband indemnifies and holds Wife harmless on account of any loss reiating to the 1994 Astro Van, including any claim by the creditor who provided purchase money for the van. (5) TANGIBLE PERSONAL PROPERTY: The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, tools and other household personal property between them, and they mutually agree that each party shall from and after the date hereof be the sole and separate owner of all such property presently in his or her possession whether said property was heretofore owned jointly or individually by the parties hereto. This agreement shall have the effect of an assignment or bill of sale from each party to the other for such property as may be in the individual possession of each of the parties hereto. (6) INTANGIBLE PERSONAL PROPERTY: Each party hereby relinquishes any right, titie or interest he or she may have in or to any intangible personal property currently titled in the name of or in the possession of the other party, including, but not limited to, stocks, bonds, insurance, bank accounts, individual retirement accounts, employment benefits including 3 .~ . retirement accounts, savings plans, pension plans, stock plans, 401 K plans and the like. (7) WAIVER OF ALIMONY: The parties acknowledge that each has income and assets satisfactory to his and her own reasonable needs. Each party waives any claim he or she may have one against the other for alimony, spousal support or alimony and alimony pendente lite. (8) ADVICE OF COUNSEL: The parties hereto acknowledge that each has been notified of his or her right to consult with counsel of his or her choice, and have been provided a copy of this agreement with which to consult with counsel. Wife is represented by Carol J. Lindsay, Esquire, of the law firm of SAlOIS, SHUFF, FLOWER & LINDSAY, 26 W. High Street, Carlisle, PA 17013, and Husband is represented by the Family Law Clinic of the Penn State Dickinson School of Law. Each party acknowledges and accepts that this agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and with such knowledge as each has sought from counsel, and the execution of this agreement is not the result of any duress or undue influence, and that it is not the result of any improper or illegal agreement or agreements. Each party shall pay his or her own attorney for all legal services rendered or to be rendered on his or her behalf. (9) ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. (10) INCOME TAX: The parties have heretofore filed joint federal and state tax returns. Both parties agree that in the event any deficiency in federal, state or local income tax is proposed. or assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for any such tax deficiency or 4 I' '. assessment and any interest, penalty and expense incurred in connection therewith. Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns. (11) BANKRUPTCY: The parties hereby agree that the provisions of this Agreement shall not be dischargeable in Bankruptcy and expressly agree to reaffirm any and all obligations contained herein. In the event a party files such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other party shall have the right to declare this Agreement to be null and void and to terminate this Agreement in which event the division of the parties' marital assets and all other rights determined by this Agreement including alimony shall be subject to court determination the same as if this Agreement had never been entered into. (12) COMPLETE DISCLOSURE: The parties do hereby warrant, represent, acknowledge and agree that each is fully and completely informed of, and is familiar with, the wealth, real and personal property, estate and assets, earnings and income of the other and has made any inquiry he or she desires into the income or estate of the other and received any such information requested. Each has made a full and complete disclosure to the other of his and her entire assets, liabilities, income and expenses and any further enumeration or statement thereof in this Agreement is specifically waived. (13) RIGHTS AND RESPONSIBILITIES: Husband and Wife acknowledge that each of them has read and understand his and her rights and responsibilities under this Agreement and that they have executed this Agreement under no compulsion to do so but as a voluntary act. (14) FULL SETTLEMENT: Except as herein otherwise provided, each party hereby releases the other from any and all claims, or demands up to the date of execution hereof. It is 5 I" 'I further specifically understood and agreed by and between the parties hereto that each party accepts the provisions herein made in lieu of and in full settlement and satisfaction of any and all of said party's rights against the other for past, present and future claims on account of support, maintenance, alimony, alimony pendente lite, counsel fees, costs and expenses, equitable distribution of marital property and any other claims of the party, including all claims which have been raised or may be raised in an action for divorce. (15) RELEASE OF ALL CLAIMS: Except as may be otherwise specifically provided in this Agreement, Husband and Wife, for themselves, their heirs, representatives and assigns, each hereby forever releases, remises, discharges and quitclaims the other, and such other's heirs, representatives, assigns and estate, from and with respect to the following: A. All liability, claims, causes of action, damages, costs, contributions and expenses or demands whatsoever in law or in equity; B. All rights, title, interest or claims in or to any property of the other, whether real, personal or mixed and whether now owned or hereafter acquired; C. All rights of courtesy and dower and all claims or rights in the nature of courtesy and dower; D. All widow or widower's rights; E. All right, title, interest or claim in or to the other's estate, whether now owned or hereafter acquired, including but not limited to all rights or claims: (1) to take against the other's will; (2) under the laws of intestacy; (3) to a family exemption or similar allowance; and (4) all other rights or authority to participate or intervene in a deceased spouse's estate in any way, whether arising under the laws of Pennsylvania or any other country, territory, state or political subdivision. 6 ~ .-::---w_~ F. All rights or claims to any accounting; G. All rights, claims, demands, liabilities and obligations arising out of or in connection with the marital relationship or the joint ownership of property, whether real, personal or mixed; H. All rights, claims, demands, liabilities and obligations arising under the provisions of the Pennsylvania Divorce Code, as the same may be amended from time to time, and under the provisions of any similar statute enacted by any other country, state, territory or political subdivision; I. All rights, claims, demands, liabilities and obligations each party now has, or may hereafter have, against or with respect to the other. (16) GOVERNING LAW: This Agreement shall be construed under the law of the Commonwealth of Pennsylvania. If any provision of this Agreement is determined to be invalid or unenforceable, all other provisions shall continue in full force and effect. (17) INCORPORATION INTO DECREE: In the event that either of the parties shall recover a final judgment or decree of absolute divorce against the other in a court of competent jurisdiction, the provisions of this Agreement may be incorporated by reference or in substance but shall not be merged into such judgment or decree and this Agreement shall survive any such final judgment or decree of absolute divorce and shall be entirely independent thereof. (18) BREACH: In the event that either party breaches any provision of this Agreement, he or she shall be responsible for any and all costs incurred to enforce the Agreement, including, but not limited to, court cost and counsel fees of the other party. In the event of breach, the other party shall have the right, at his or her election; to sue for damages for such breach or to seek such other and additional remedies as may be available to him or her. (19) ENTIRE UNDERSTANDING: This Agreement constitutes the entire understanding 7 'c '\ ... between the parties and there are no covenants, conditions, representations, or agreements, oral or written, of any nature whatsoever, other than those herein contained. (20) AGREEMENT BINDING ON PARTIES AND HEIRS: This Agreement shall bind the parties hereto, their respective heirs, executors and assigns. IN WITNESS WHEREOF, the parties hereto intending to be legally bound have hereunto set their hands and seals the day and year first written above. WITNESS: 7 { , , ". "~i. r";;, l '. t (/, /. alAI ( cl t? ,.'-"- JULIAN~ GLASS . . L../,.r: ,.;,:/ A: <:.<,.. J.'~' rt7"/, .~ ..:.:.. -~ /;) '4~/C --- ('i.~ J --1JL CHRIST PHER GLASS 8 Christopher Glass, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION- LAW : IN DIVORCE AND CUSTODY Juliane Glass, Defendant : No. 04-6119 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information, to the court for entry of a divorce decree: I. Ground for divorce: irretrievable breakdown under ~330 I (c) ofthe Divorce Code. 2. Date and manner of service of the complaint: December 23, 2004 by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. 3. Date of execution of the affidavit of consent required by ~3301 (c) of the Divorce Code: by plaintiff, January 19,2006; by defendant, April 7,2006. 4. Related claims pending: none 5. Date plaintiff's Waiver of Notice in 9330I(c) Divorce was filed with the Prothonotary: January 19,2006 Date defendant's Waiver of Notice in 93301(c) Divorce was filed with the Prothonotary: April 7,2006. s /; Ir;'f./ Date I ~' / ~/ /. / " "'~tL, )21' /l:.~ \ 'Lauren Navalkowsky / Certified Legal Intern ~ (' /~ ( " J / ./ . . '. . /1,', f, ;. I'" I. ''1- -r',/ "...... l,,,,,,,-',,'-I_ .-<... -/ . J Anne nald-Fox, tSsg. Supervi mg Attorneys F AMIL Y LAW CLINIC 45 N. Pitt Street Carlisle, P A 17013 717-243-2968 Fax: 717-243,3639 Attorneys for Plaintiff ++.:+::+: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '.. .. .. . . +.:+::+:+.:+: :+:+.:+:+. .. . :+: +':+: +.:+: + + ++ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . +'+.+.+.:+:+.~:+::+:+.+.:+:+.+.+.+.+.+.+. +.:+. +' +.:+: +':+: '+' +.:+: +. +.:+. + + :+: .. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF Christopher Glass Plaintiff VERSUS Juliane Glass Defendant AND NOW, DECREED THAT AND PEN NA. No. 2004 6119 DECREE IN DIVORCE /YI' .?d , IT IS ORDERED AND :2<>0 (, Christopher Glass , PLAINTIFF, Juliane Glass , DEFENDANT, OURTJ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . +'+''1':++'1''1':+::+++'+:+:+ ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT Nonp :+::+:+:+ PROTHONOTARY :+:+:+:+::++:+:+:++.:+:+.:+::+:+:+::++.:++:+:+::+:+:+:+: +:+:'f'f'f+'+':+'+'++ +'+:+:'f+:+:+'f'f'+:f.:+:+:+:+: J. . 7.-7 2. fT:~?J'1/ '?)!~/7 ,2. /rZ>11Y 4'O>v'/'(} . " ~7'h I '7(/- .h. r. - //.-7